state implementation plan

Complying with 111(d)

Exploring the cap-and-invest option.

EPA is expected to provide states with latitude in meeting Clean Air Act GHG standards. The Regional Greenhouse Gas Initiative (RGGI) demonstrates an effective and economical approach: “cap and invest.”

Least-Risk Planning

The Homer City decision increases uncertainty—but rewards forward thinking.

The D.C. Circuit’s CSAPR ruling reinforces the benefits of planning ahead and keeping options open. A diverse portfolio strategy reduces risks and costs.